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14 04 09 Jenkins Complaint

14 04 09 Jenkins Complaint

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Published by Jeff Quinton
ACLJ's legal complaint against the Community College of Baltimore County, Maryland on behalf of Brandon Jenkins.
ACLJ's legal complaint against the Community College of Baltimore County, Maryland on behalf of Brandon Jenkins.

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Published by: Jeff Quinton on Apr 23, 2014
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04/29/2014

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1
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND BRANDON JENKINS, Plaintiff, v. SANDRA KURTINITIS, individually and in her official capacity as President, COMMUNITY COLLEGE OF BALTIMORE COUNTY MARK MCCOLLOCH, individually and in his official capacity as Vice President of Instruction, COMMUNITY COLLEGE OF BALTIMORE COUNTY RICHARD LILLEY, individually and in his official capacity as Vice President of Enrollment and Student Services, COMMUNITY COLLEGE OF BALTIMORE COUNTY and ADRIENNE DOUGHERTY, individually and in her official capacity as Program Director and Coordinator of Radiation Therapy, COMMUNITY COLLEGE OF BALTIMORE COUNTY CIVIL ACTION NO.
 
2
Defendants. VERIFIED COMPLAINT
Plaintiff, Brandon Jenkins, by and through counsel, brings this action for relief against Sandra Kurtinitis, President of The Community College of Baltimore County, Baltimore, Maryland
(“CCBC”)
; Mark McColloch, Vice President of Instruction at CCBC; Richard Lilley, Vice President of Enrollment and Student Services at CCBC; and Adrienne Dougherty, Program Director and Coordinator of Radiation Therapy at CCBC, and hereby states as follows:
INTRODUCTION
1.
 
In April 2013,
following Mr. Jenkins’s completion of the admission requirements and
 process for acceptance to CCBC
’s
Radiation Therapy Program, whereby he met the standards of a competitive candidate and scored the maximum points allowed during his observation, Mr. Jenkins was informed that he would not be admitted to the program in part because the
college viewed religion to be a major part of Mr. Jenkins’s life
, and, as one faculty member explained on behalf of CCBC
, the “field [of radiation therapy] is not the place for religion.”
 2.
 
Mr. Jenkins made several attempts to address with Defendants the discriminatory reasoning upon which they denied Mr. Jenkins admission to the program: retaliation as a result of his expression of his religious views. Defendants,
however, affirmed Defendant Dougherty’s
initial determination not to admit Mr. Jenkins to the program and the reasoning upon which she relied. 3.
 
This lawsuit seeks damages, a declaratory judgment, and injunctive relief requiring
Defendants to accept Mr. Jenkins into CCBC’s Radiation Therapy Program and prohibiting them
 
3 from further retaliating and/or discriminating against Mr. Jenkins based on his religious views and/or his expressions thereof.
JURISDICTION AND VENUE
4.
 
This action raises federal questions under the First Amendment to the United States Constitution and 42 U.S.C. § 1983.
 
5.
 
This Court has original jurisdiction over these federal claims pursuant to 28 U.S.C. §§ 1331 and 1343, and supplemental jurisdiction over the state claim pursuant to 28 U.S.C. § 1367. This Court has authority to award the requested damages pursuant to 28 U.S.C. § 1343 and 42 U.S.C. § 1983; the requested declaratory relief pursuant to 28 U.S.C. §§ 2201-
02; and costs and attorneys’ fees
 pursuant to 42 U.S.C. § 1988. 6.
 
Venue is proper in this district pursuant to 28 U.S.C. § 1391(e) because Defendants reside in this district and/or all of the acts described in this Complaint occurred in this district.
PARTIES
7.
 
Brandon Jenkins is a private citizen and prospective student for the Radiation Therapy Program at CCBC. 8.
 
Defendant Sandra Kurtinitis serves as the President of CCBC. President Kurtinitis is the official through whom the CCBC Board of Trustees carries out its policies. She is responsible for the conduct and operation of the college and for the administration and supervision of its departments. 9.
 
Defendant Mark McColloch serves as the Vice President of Instruction at CCBC. According to
the college’s
website, Defendant McColloch is a member of the P
resident’s Senior
Staff and serves as an educational leader, not just a manager, functioning as part of a senior level

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